NL-14-032, Supplemental Information to Proposed Changes to Indian Point 2 Technical Specifications Regarding Reactor Vessel Heatup and Cooldown Curves and Low Temperature Over Pressure Requirements Indian Point Unit Number 2

Supplemental Information to Proposed Changes to Indian Point 2 Technical Specifications Regarding Reactor Vessel Heatup and Cooldown Curves and Low Temperature Over Pressure Requirements Indian Point Unit Number 2

ML14069A306
Person / Time
Site:	Indian Point
Issue date:	02/24/2014
From:	Ventosa J Entergy Nuclear Northeast, Entergy Nuclear Operations
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-14-032
Download: ML14069A306 (7)

Text

Enterav Nuclear Northeast

- Entergy, Indian Point Energy Center 450 Broadway, GSB P.O. Box 249 Buchanan, NY 10511-0249 Tel 914 254 6700 John A Ventosa Site Vice President Administration NL-14-032 February 24, 2014 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk 11555 Rockville Pike Rockville, MD 20852

SUBJECT:

Supplemental Information to Proposed Changes to Indian Point 2 Technical Specifications Regarding Reactor Vessel Heatup and Cooldown Curves and Low Temperature Over Pressure Requirements Indian Point Unit Number 2 Docket No. 50-247 License No. DPR-26

REFERENCES:

1. Entergy Letter NL-13-123 to NRC, Response to Request for Additional Information Regarding License Amendment Request concerning PT-Limits and LTOP Requirements (TAC NO. MF0634), dated October 3, 2013.

2. Entergy Letter NL-13-081 to NRC, Response to Request for Additional Information Regarding License Amendment Request concerning PT-Limits and LTOP Requirements (TAC NO. MF0634), dated July 9, 2013.

3. NRC Letter to Entergy, Request for Additional Information Regarding License Amendment Request concerning PT-Limits and LTOP Requirements (TAC NO. MF0634), dated June 13, 2013.

4. Entergy Letter NL-13-001 to NRC, Proposed Changes to Indian Point 2 Technical Specifications Regarding Reactor Vessel Heatup and Cooldown Curves and Low Temperature Over Pressure Requirements, dated February 6, 2013.

Dear Sir or Madam:

Entergy Nuclear Operations, Inc., (Entergy) is submitting the attached supplemental information to Proposed Changes to Indian Point 2 Technical Specifications Regarding Reactor Vessel Heatup 41/2z1<Df

NL-14-032 Docket 50-247 Page 2 of 2 and Cooldown Curves and Low Temperature Over Pressure Requirements (Reference 4). This supplemental information addresses an issue regarding the applicability of Figures 3.4.3-1 and 3.4.3-2 during vacuum fill of the RCS. Specifically, the NOTES on Figures 3.4.3-1 and 3.4.3-2 now also state that the Figures and minimum bolt-up temperature are applicable during vacuum fill.

Further, a clarification statement is being proposed for inclusion in the Technical Specifications Bases, and attached for information. Please replace Figures 3.4.3-1 and 3.4.3-2 in Reference 4 with the attached Figures.

There are no new commitments being made in this submittal. If you have any questions or require additional information, please contact Mr. Robert Walpole, Manager, Regulatory Assurance at (914) 254-6710.

I declare under penalty of perjury that the foregoing is true and correct. Executed on February L4, 2014.

Sincerely, JAV/ai Attachments:

1. Technical Specifications Replacement Figures 3.4.3-1 and 3.4.3-2

2. Markup of Technical Specifications Bases Page B 3.4.3-1 for Proposed Changes regarding Reactor Heatup and Cooldown Curves and LTOP Requirements cc: Mr. Douglas Pickett, Senior Project Manager, NRC NRR DORL Mr. William Dean, Regional Administrator, NRC Region 1 NRC Resident Inspectors Office Mr. Francis J. Murray, Jr., President and CEO, NYSERDA Ms. Bridget Frymire, New York State Dept. of Public Service

ATTACHMENT 1 TO NL-14-032 TECHNICAL SPECIFICATIONS REPLACEMENT FIGURES 3.4.3-1 AND 3.4.3-2 Unit 2 Affected Pages:

3.4.3-3 3.4.3-4 ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 DOCKET NO. 50-247

RCS P/T Limits 3.4.3 2500 2000 L.

to 1500 CL, E 1000 E

x MU 500 0

0 50 100 150 200 250 300 350 400 450 500 550 RCS Temperature (OF)

Figure 3.4.3-1:

Heatup Limitations for the Reactor Coolant System (RCS) and Hydrostatic and Inservice Leak Testing Limitations for the RCS.

INDIAN POINT 2 3.4.3- 3 Amendment No. 274

RCS P/T Limits 3.4.3 2500 NOTES:

- Applicable to 48 EFPY and during vacuum fill -o-Cooldown Rate - Steady State

- No Allowance for Instrument Error or Pressure Bias

- Minimum bolt-up temperature remains applicable dunng -Cooldown Rate - 20 *F/Hr vacuum fill

--mCooldown Rate - 40 *FIHr 2000 --wCooldown Rate - 60 *F/Hr Cooldown Rate - 100 *FIHr 1500 Unacceptable Operation L(To Left or Above Opplcberation )

E.

E L.

1000 7 Acceptable Operation 7 (To Right or Below Applicable Curv 500 Bol8-up Temperature 60 °F 0

0 50 100 150 200 250 300 350 400 450 500 550 RCS Temperature (OF)

Figure 3.4.3-2:

Cooldown Limitations for the RCS (including RCS cooldown following RCS inservice leak and hydrostatic testing)

INDIAN POINT 2 3.4.3-4 Amendment No. 274

ATTACHMENT 2 TO NL-14-032 MARKUP OF TECHNICAL SPECIFICATIONS BASES PAGE B 3.4.3-1 FOR PROPOSED CHANGES REGARDING REACTOR HEATUP AND COOLDOWN CURVES AND LTOP REQUIREMENTS Text changes indicated by Bold/Italics for additions Unit 2 Affected Page:

3.4.3-1 ENTERGY NUCLEAR OPERATIONS, INC.

INDIAN POINT NUCLEAR GENERATING UNIT NO. 2 DOCKET NO. 50-247

RCS P/T Limits B 3.4.3 B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.3 RCS Pressure and Temperature (P/T) Limits BASES BACKGROUND All components of the RCS are designed to withstand effects of cyclic loads due to system pressure and temperature changes. These loads are introduced by startup (heatup) and shutdown (cooldown) operations, power transients, and reactor trips. This LCO limits the pressure and temperature changes during RCS heatup and cooldown, within the design assumptions and the stress limits for cyclic operation.

Figure 3.4.3-1, "Heatup Limitations for the Reactor Coolant System (RCS) and Hydrostatic and Inservice Leak Testing Limitations for the RCS," and Figure 3.4.3-2, "Cooldown Limitations for the RCS (including RCS cooldown following RCS inservice leak and hydrostatic testing)," contain P/T limit curves for heatup, cooldown, inservice leak and hydrostatic (ISLH) testing, and data for the maximum rate of change of reactor coolant temperature (References 1 and 8 ).

Each P/T limit curve defines an acceptable region for normal operation.

The usual use of the curves is operational guidance during heatup or cooldown maneuvering, when pressure and temperature indications are monitored and compared to the applicable curve to determine that operation is within the allowable region. Vacuum fill of the RCS is performed in Mode 5 under sub-atmospheric pressure and isothermal RCS conditions. Vacuum fill is an acceptable condition since the resulting pressure/temperaturecombination is located in the region to the right and below the operating limits provided in Figures3.4.3-1 and 3.4.3-2.

The LCO establishes operating limits that provide a margin to brittle failure of the reactor vessel and piping of the reactor coolant pressure boundary (RCPB). The vessel is the component most subject to brittle failure, and the LCO limits apply mainly to the vessel. The limits do not apply to the pressurizer, which has different design characteristics and operating functions.

10 CFR 50, Appendix G (Ref. 2), requires the establishment of P/T limits for specific material fracture toughness requirements of the RCPB materials. Reference 2 requires an adequate margin to brittle failure during normal operation, anticipated operational occurrences, and system hydrostatic tests. It mandates the use of the American Society of Mechanical Engineers (ASME) Code,Section III, Appendix G (Ref. 3).

The neutron embrittlement effect on the material toughness is reflected by increasing the nil ductility reference temperature (RTNDT) as exposure to neutron fluence increases.

INDIAN POINT 2 B 3.4.3 - 1 Revision 2